General comment: please consider constructing eCQMs to apply to all sites providing services to Medicare beneficiaries and not just to those sites currently using certified EHRs.  This change in focus has three important implications: 1. it requires more information about the individual (goals, preferences, priorities, capabilities), 2. it emphasizes the importance of information sharing between/among a more extensive list of sites/service providers, and 3. it requires data elements required to assess the quality of transitions of care given their importance for quality and safety.

With this comment in mind, please consider adding the following:

Advance Directives: source (individual, family, caregiver, HCP, etc)

Advance Directives: Treatment preferences

Individual Characteristics: ability to communicate goals, preferences, and priorities

Individual Characteristics: ability to establish goals, preferences, and priorities

Individual Characteristics: ability to consent to treatment and information use

Medications: indication

Medications: reason for change (formulary, adverse reaction)

Social Determinants of Health

 

Ideally, eCQMs for transitions of care should capture completeness and timeliness of the information shared.

Thank you.